Full Disclosure

Revised August 2018

General Disclosures

Wealthfront Advisers LLC (“Wealthfront Advisers”, the successor investment adviser to Wealthfront Inc.) is an SEC-registered investment adviser and a wholly owned subsidiary of Wealthfront Corporation (formerly known as Wealthfront Inc.).

Wealthfront Corporation (formerly known as Wealthfront Inc.) and its affiliates operate a website at www.Wealthfront.com and/or our mobile applications ("our website" (which includes our blog), "our app" or "Wealthfront"). Wealthfront Advisers LLC (“Wealthfront Advisers,” the successor investment adviser to Wealthfront Inc.) is registered with the Securities and Exchange Commission under the Investment Advisers Act of 1940, as amended, and is a wholly owned subsidiary of Wealthfront Corporation.

Wealthfront Advisers provides investment advisory services to clients, but does not provide personalized financial planning to investors, such as estate, tax, or retirement planning. Nothing on this Site or App should be construed as a solicitation or offer, or recommendation, to buy or sell any security. Advisory services are only provided to investors who become advisory clients of Wealthfront Advisers ("Clients") pursuant to a written Advisory Client Agreement , which investors are urged to read and carefully consider in determining whether such agreement is suitable for their individual facts and circumstances. (Part 2 of Wealthfront Advisers’ Form ADV is available at: https://www.wealthfront.com/static/documents/form_adv_part_2.pdf.)

PAST PERFORMANCE IS NO GUARANTEE OF FUTURE RESULTS, AND ANY EXPECTED RETURNS OR HYPOTHETICAL PROJECTIONS MAY NOT REFLECT ACTUAL FUTURE PERFORMANCE. FURTHERMORE, PAST RETURNS MAY REFLECT THE PERFORMANCE OF ASSETS FOR A FINITE TIME, OR DURING A PERIOD OF EXTREME MARKET ACTIVITY. ALL INVESTMENTS INVOLVE RISK AND MAY LOSE MONEY. There can be no assurance that an investment mix or any projected or actual performance shown on the Site or App will lead to the expected results shown or perform in any predictable manner. It should not be assumed that investors will experience returns in the future, if any, comparable to those shown or that any or all Clients actually experienced such returns.

Wealthfront Advisers’ investment strategies, including portfolio rebalancing and tax loss harvesting, can lead to high levels of trading. High levels of trading could result in (a) bid-ask spread expense; (b) trade executions that may occur at prices beyond the bid ask spread (if quantity demanded exceeds quantity available at the bid or ask); (c) trading that may adversely move prices, such that subsequent transactions occur at worse prices; (d) trading that may disqualify some dividends from qualified dividend treatment; (e) unfulfilled orders or portfolio drift, in the event that markets are disorderly or trading halts altogether; and (f) unforeseen trading errors.

As part of transferring your account to Wealthfront Advisers, we will apply our algorithms to sell your transferred account, seeking to minimize any potentially negative tax impact and optimizing for other factors, and invest the proceeds into a Wealthfront portfolio. Liquidating your transferred account may cause, among other things, realized capital gains or losses in specific securities, surrender fees, and redirection of declared dividends or distributions. Also be aware selling down securities prior to transfer could subject you to the same risks.

All product names, logos, and brands are property of their respective owners. Use of these names, logos, and brands is for identification purposes only, and does not imply endorsement or affiliation.

Wealthfront Advisers Process

Wealthfront Advisers' methodology is based on Modern Portfolio Theory, for which the Nobel Prize was awarded in 1990. It is considered state-of-the-art portfolio modeling, but is only one possible way to invest. Clients should be aware that Wealthfront Advisers’ process is based in part on a careful evaluation of past price performance and volatility in order to evaluate future probabilities. Although Wealthfront Advisers seeks multiple asset classes for its Clients in order to diversify portfolios, it is possible that different or unrelated asset classes may all exhibit similar price changes in similar directions. This correlation of price behavior may adversely affect a Client, and may become more acute in times of market upheaval or high volatility.

ETF Selection Disclosures

The securities employed in Client accounts are exchange-traded funds or other publicly registered funds ("ETFs"), which generally are registered investment companies under the Investment Company Act of 1940. Although Wealthfront Advisers believes its selection process identifies ETFs with high liquidity, low expenses, and low tracking error, Wealthfront Advisers’ selection process does not guarantee the quality of a particular ETF or that it will 1) be profitable, 2) properly track any comparable index, 3) trade in a liquid fashion, or 4) trade at or above its publicly-posted net asset value.

Wealthfront Advisers reserves the right to change at any time the selection of ETFs that it recommends if, in Wealthfront Advisers’ sole discretion, any ETF does not meet requirements for continued listing on the platform. Clients should be aware that changes in the selection of ETFs employed by Wealthfront Advisers’ investment management service may result in the sale of their existing holdings and may subject them to additional tax liability.

ETFs are only one type of securities product, and Wealthfront Advisers generally does not make available to Clients other types of securities products that an investor may wish to consider as part of his or her overall financial plan. Other ETFs or investment products may provide different performance.

ETF Fee and Performance Disclosure

An ETF typically includes embedded expenses that may reduce its net asset value, and therefore directly affect its performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. These expenses may include management fees, custodian fees, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. Wealthfront Advisers discloses each ETF’s current information, including expenses, on the Site or App. ETF tracking error and expenses may vary.

Furthermore, ETF performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF incurs expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF.

Certain ETF strategies may from time to time include fixed income, commodities, foreign securities, American Depositary Receipts, or other securities for which expenses could be higher than otherwise charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate.

Clients should be aware that in some limited instances it may be difficult or impossible to trade the Clients’ securities. This liquidity risk may be caused by numerous factors, including but not limited to: 1) extreme market volatility, 2) a decision by exchange participants to withhold some or all of their quoted market bids, 3) exchange technical issues or exchange closure, 4) delisted or halted securities, and/or 5) a position across Client accounts that is large relative to the average daily trading volume of the security.

Performance Disclosures

Performance information is presented net of all management fees and expenses unless marked otherwise. Commissions are not considered since Clients on the Wealthfront Advisers’ platform are not charged trading commissions. For all periods the performance information includes the reinvestment of dividends and interest unless otherwise noted.

Any comparison to traditional financial advisors is based on an evaluation of average fees and returns. Actual results may be different for each investor and there can be no guarantee of enhanced returns due to additional diversification, ETF selection, or the use of Wealthfront Advisers’ investment management service.

Projected and/or hypothetical performance is intended to show only an expected range of possible investment outcomes based on historical average returns and standard deviation of each investment type contained in the investment mix recommended by Wealthfront Advisers, but does not take into consideration the effect of taxes, changing risk profiles, or future investment decisions. Projected and/or hypothetical performance does not represent actual Client accounts or actual trades and may not reflect the effect of material economic and market factors. The actual transaction costs in Client accounts may be different.

Actual investors that become Clients may experience different results from any hypothetical results shown. There is a potential for loss, as well as gain, that is not reflected in the hypothetical information portrayed. The hypothetical performance results shown do not represent the results of actual trading using client assets but were achieved by means of the retroactive application of a model designed with the benefit of hindsight. Investors should carefully review the additional information presented by Wealthfront Advisers as part of any hypothetical comparison.


The return, composite and performance information shown on the Site or App uses or includes information compiled from third-party sources, including independent market quotations and index information. Wealthfront Advisers believes the third-party information comes from reliable sources, but Wealthfront Advisers does not guarantee the accuracy of the Site or App information and may receive incorrect information from third-party providers. Unless otherwise indicated, the information on the Site or App has been prepared by Wealthfront Advisers and has not been reviewed, compiled or audited by any independent third-party or public accountant.

Fee and Account Disclosures

Recommendations and fees may vary for each Client. Advisory fees are calculated based upon the amount of assets being managed (as detailed further in Wealthfront Advisers’ Form ADV Part 2).

Wealthfront Advisers does not make any representations regarding the execution quality of orders placed with our executing broker-dealer partner. However, Wealthfront Advisers does monitor the execution quality of transactions to ensure that Clients receive the best overall trade execution pursuant to regulatory requirements.

Description of "Free." Certain ETF products, offered through Wealthfront Advisers, may be free of commissions; however, management and/or other fees may be charged for investment products managed by outside companies, which are unaffiliated entities of Wealthfront Advisers.

Tax And Tax-Loss Harvesting Disclosures

Wealthfront Advisers does not represent in any manner that the tax consequences described as part of its tax-loss harvesting service will be achieved or that Wealthfront Advisers’ tax-loss harvesting service, or any of its products and/or services, will result in any particular tax consequence. The tax consequences of the tax-loss harvesting service and other strategies that Wealthfront Advisers may pursue are complex and uncertain and may be challenged by the IRS. The information with regard to this service was not prepared to be used, and it cannot be used, by any investor to avoid penalties or interest.

Clients should confer with their personal tax advisors regarding the tax consequences of investing with Wealthfront Advisers and engaging in the tax-loss harvesting service, based on their particular circumstances. Clients and their personal tax advisors are responsible for how the transactions conducted in an account are reported to the IRS or any other taxing authority on the Client’s personal tax returns. Wealthfront Advisers assumes no responsibility for the tax consequences to any Client of any transaction.

The performance of the new securities purchased through the tax-loss harvesting service may be better or worse than the performance of the securities that are sold for tax-loss harvesting purposes. The utilization of losses harvested through the strategy will depend upon the recognition of capital gains in the same or a future tax period, and in addition may be subject to limitations under applicable tax laws, e.g., if there are insufficient realized gains in the tax period, the use of harvested losses may be limited to a $3,000 deduction against income and distributions. Losses harvested through the strategy that are not utilized in the tax period when recognized (e.g., because of insufficient capital gains and/or significant capital loss carryforwards), generally may be carried forward to offset future capital gains, if any. Wealthfront Advisers only monitors for tax-loss harvesting for accounts within Wealthfront Advisers. The client is responsible for monitoring their and their spouse's accounts outside of Wealthfront Advisers to ensure that transactions in the same security or a substantially similar security do not create a “wash sale.” A wash sale is the sale at a loss and purchase of the same security or substantially similar security within 30 days of each other. If a wash sale transaction occurs, the IRS may disallow or defer the loss for current tax reporting purposes. More specifically, the wash sale period for any sale at a loss consists of 61 calendar days: the day of the sale, the 30 days before the sale, and the 30 days after the sale. The wash sale rule postpones losses on a sale, if replacement shares are bought around the same time. Wealthfront Advisers may lack visibility to certain wash sales, should they occur as a result of external or unlinked accounts, and therefore Wealthfront Advisers may not be able to provide notice of such wash sale in advance of the Client's receipt of the IRS Form 1099. The effectiveness of the tax-loss harvesting strategy to reduce the tax liability of the Client will depend on the Client’s entire tax and investment profile, including purchases and dispositions in a Client’s (or Client’s spouse’s) accounts outside of Wealthfront Advisers and type of investments (e.g., taxable or nontaxable) or holding period (e.g., short- term or long-term). Except as set forth below, Wealthfront Advisers will monitor only a Client’s (or Client’s spouse’s) accounts at Wealthfront Advisers to determine if there are unrealized losses for purposes of determining whether to harvest such losses. Transactions outside of such accounts may affect whether a loss is successfully harvested and, if so, whether that loss is usable by the Client in the most efficient manner. A Client may also request that Wealthfront Advisers monitor the Client’s spouse’s accounts or their IRA accounts at Wealthfront Advisers to avoid the wash sale disallowance rule. A Client may request spousal monitoring online or by calling Wealthfront Advisers at 844.995.8437. If Wealthfront Advisers is monitoring multiple accounts to avoid the wash sale disallowance rule, the first taxable account to trade a security will block the other account(s) from trading in that same security for 30 days.